With the short lives of some of our commercial buildings, embodied emissions may make up more than half of their total lifetime impact. Yet government has turned its face away from a sustainable materials standard, and industry are dragging their feet quite unnecessarily, argues AECB member Gary Newman, a founder of the Alliance for Sustainable Building Products.

The government recently turned down the opportunity to make a dramatic impact on the emissions of our building stock, by declining to bring in a standard for the embodied impact of new buildings. Yet the arguments advanced are weak and defeatist .

In its response to comments on the Housing Standards Review,[1] the Department for Communities and Local Government “did not consider that there was sufficient evidence to suggest the need for a Building Regulation or national standard on sustainable materials for homes,” …“not least because of the operation of European legislation and standards in this field”. (DCLG generously adds however that “The Government does not object to industry taking forward voluntary, self policed standards.” )

Meanwhile the UKGBC’s Zero Carbon Non Domestic Task Group, in its report Building Zero Carbon the case for action, makes the case for action on capital carbon — “in time”.[2] The Task Group also points to (or hides behind?) the ongoing harmonisation process around the use of the European standard format for reporting embodied impact. [3] Yet adequate tools and standards already exist to enable meaningful embodied impact assessment in almost all situations.[4]

And the wait for European harmonisation has not prevented other European nations adopting standards, as DCLG has noted. For example, the Netherlands has enforced the reporting of embodied carbon for new housing and offices, based on a national database and national method that reflects the same European standard currently undergoing ‘harmonisation’. Dutch assessors have adapted their existing tools to the national standard. It would be perfectly possible to achieve something similar in the UK, using the tools being developed here.

Now I’m not saying that is definitely what we should do here, but we need to have the discussion, and have it now! Until we set a date for introducing a standard, we are never going to have the important dialogue between industry, government and other stakeholders that has to take place in order to develop a meaningful , workable system. Putting it off again and again gets us absolutely nowhere.

Why should we act now? Firstly, the wins are substantial . In non-domestic buildings, many with relatively short lives, the embodied impact of the fabric might be more than 50% of the entire lifetime impact of the building. Apart from anything else, if the zero carbon standards for buildings is to be remotely credible, ignoring 50% of the building carbon impact is hardy going to help.[5]

Savings made in embodied impact happen now: they are measurable and cannot be lost through changes in occupier behaviour, or new types of technology. Yet UKGBC is proposing we bring in new standards for energy use of appliances and equipment (such as escalators and lifts) – although these savings happen in the future, and are therefore inherently uncertain – before we tackle a completely verifiable pallet of bricks.

There is also an opportunity for the net sequestration of carbon through the use of biogenic building materials, with research by ASBP (for DECC) showing that this could potentially exceed the scale of the entire Zero Carbon Homes policy by 2020.

Pressure to reduce impact drives innovation. Setting a date for regulation in the field of embodied impact would give a tangible incentive to forward-looking companies to invest in sustainable products: the UKGBC itself argues that “greater policy certainty about future changes to the non-domestic Building Regulations will enable economic growth and unlock significant carbon emissions reductions”.

Can materials standards protect building quality?

The much-lamented performance gap is not just a result of inconsistent construction, but also “value engineering”, where the qualities of specific products (including technical performance and embodied impacts, as well as appearance) are sacrificed for cost saving – a materials standard would make this kind of substitution harder to get away with, as a second metric would be at stake.

I’m not just talking about a calculus for embodied carbon and energy. There are equally important measures which could be taken now, that would have a huge impact on future energy and resource use. For example, we could start by saying every commercial building over a certain size has to be designed for deconstruction. This would be simple, and not unfair on any particular material.

Something like that would change the way we use all resources; it’s not simply about finding alternative materials, as some people think – some of the biggest carbon and resource wins can come from using conventional materials more intelligently. For example steel is one of the easiest materials to use again and again.

At the “Resource” event at Ecobuild the ASBP were promoting their RE-Fab project for standardised, compatible, “fix-together” units, across different manufacturers, offering potential for easily assembled and disassembled buildings that would be made up of elements that have a resale/reuse value. Designers loved this idea, because of the effect on how buildings are valued – it would make specifying the very best products, even in a commercial building with a 30-year life, a viable option.

Re-use and resource efficiency goes with the grain of what makes economic sense anyway, but as with operational energy consumption, the market is failing, and regulation is needed to get people making choices that look beyond the short-term to the longer-term advantage for all.There is of course the ‘no more red tape’ argument, but common standards are the basis of all trade in a well-organised society; the alternative is a race to the bottom. A standard only becomes red tape when it adds nothing to what you already have; thus in my opinion the Code for Sustainable Homes was a prime example of red tape, because it brought little or no additionality. I entirely applaud the decision to see the end of the Code for Sustainable Homes – it was a bureaucratic tangle of standards, many of which may have been perfectly reasonable on their own, but roped together and imposed right at the start of the planning process, they were an absolute nonsense.

It is somewhat inconsistent of UKGBC though, to call for maintenance of the Code, which itself contains an embodied impact standard, and then suggest that embodied impact should not form part of the zero carbon definition for non-domestic buildings, due to a lack of an agreed methodology.

This foot-dragging is letting the perfect (and, perhaps, the perfectly quiet life?) be the enemy of the good, and wantonly disregarding the huge emissions savings that could be made now, merely (the argument runs) to avoid having to adjust the standard later on.

Embodied impact assessment is a growing and developing field, but to ignore the issue on this basis is extremely short sighted. While it is important that all standards are as clear, transferrable and credible as possible, if we wait for industry consensus before we move forward, we might go round in circles forever. Industry will only apply itself to developing that consensus when we have a firm date for standards to be introduced.

Energy use has been in the building regulations since 1975, and of course we are still arguing about exactly how that should be measured. Industry disagreement cannot be a reason for inaction. In fact it is only action that will get the industry to engage. We should be discussing how we do it, starting now, with a clear timetable in mind — not just arguing about when.

Gary Newman

Gary is a founder and Executive Chair of the Alliance for Sustainable Building Products (www.asbp.org.uk). The ASBP is committed to promoting product sustainability, resource use and the principles of the circular economy. Gary is a construction engineer by training and early career; after a masters in wood science, he established Plant Fibre Technology and has brought a number of plant-based construction products from concept to market.

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[1] Government response to the Environmental Audit Committee Report: Code for Sustainable Homes and the Housing Standards ReviewMarch 2014

[2] From the report: “Government policy, in time, should seek to reduce and offset, or otherwise address … the capital carbon associated with the construction of buildings (embodied carbon)”

[3] “Voluntary harmonisation is underway via the ECO platform, an umbrella organisation for European EPD programmes, which is coordinating its activities with CEN/TC 350. As harmonised Standards emerge from CEN they will be adopted by voluntary EPD Programmes. However, in the short to medium term there remains some variability between EPD produced to EN 15804. This is why the group believes that embodied carbon calculations would not be reliably feasible in a regulatory environment until 2022 – 2025.”

[5] The UKGBC task force also rightly identifies the opportunities offered by BIM for achieving improvements in the carbon performance in buildings beyond the current focus on energy in use. But failing to address embodied impacts of building products and materials undermines the very starting point for assessing the lifecycle of a building. This failure would leave these BIM carbon claims on very shaky ground.

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